Avanade Privacy Policy

This privacy statement is effective as of May 25, 2018. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.

We encourage you to review our privacy policy whenever you visit our website to make sure that you understand how your information will be used.

GENERAL

Thank you for visiting the Avanade website (“the website” or “site”). This online privacy policy explains how Avanade, Inc. (“Avanade”; “we”) protects your personal data, what your rights are in relation to your personal data, and how we will collect and use information from our website so that you can make informed decisions about using this site. You will also find additional information on this page about how website data, marketing data and personal data are processed by Avanade.

This section (“General”) provides an overview of how Avanade protects the privacy of users and visitors to the site. Following the General section we have provided additional, more specific detail around how the Avanade website is used to collect data. If you have any questions concerning data privacy, please see our contact information at, "Contact Us", below.

Avanade’s data privacy practices

This section summarizes Avanade’s data privacy policies.

Information We Collect

Use of Personal Data

Purposes of Processing Personal Data

Information Sharing

Sensitive Personal Data

Protecting your personal data

Your safe use of our Site

Processing of Personal Data

Retention of Personal Data

Your Rights

Privacy Questions and Concerns

Data We Collect

We collect personal data of our workers, job candidates, suppliers, business contacts, shareholders and website users. We will always try to give individuals appropriate notice of what data will be collected and how it will be used. Whatever happens, we will only process that data if we consider it fair and lawful to do so. Except for certain information that we are required to collect by law, your decision to provide any personal data to us is voluntary. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement. The data we collect may include information about you or your experiences with Avanade. For example, name and contact information; relationship with Avanade; and device data.

The personal data we process has been obtained from you or from certain third parties. Such third parties may include our affiliates, public authorities, public websites and social media, suppliers and vendors.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with Avanade.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). These third parties may include our affiliates, public authorities, public websites and social media, suppliers and vendors.

Use and Purposes of Processing Personal Data

Avanade uses your personal data only where required for specific purposes. Below is a list of the purposes for which Avanade uses your personal data and an overview of the legal basis for each purpose.

Purpose

Legal Basis

Managing our contractual and/or employment relationship with you.

Necessary for the performance of a contract to which you are a party.

Recruitment.

Justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees.

Facilitating communication with you (including in case of emergencies, and to provide you with requested information).

Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.

Operating and managing our business operations.

Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.

Complying with legal requirements.

Necessary for the compliance with a legal obligation to which we are subject.

Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).

Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.

Improving the security and functioning of our website, networks and information.

Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.

Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within Avanade and/or to provide a better user experience. More details on how we run analytics on our website can be found in our cookies policy.

Justified on the basis of our legitimate interests, such as conducting and increasing our business.

Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing?” below).

Justified on the basis of our legitimate interests, such as conducting and increasing our business.

Where the above table states that we rely on our legitimate interests for a given purpose, we believe that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. Please contact us if you wish to obtain further information on this balancing test approach.

We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Information Sharing

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such outside parties may be located in other countries. Before we do so, we take steps to ensure that your personal data will be given adequate protection as required by relevant data protection laws and Avanade’s internal policies. If you are located in the European Union (“E.U.”) or European Economic Area (“EEA”), unless you are otherwise notified, any transfer of your personal data to third parties outside the EEA or EU will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data, will take place in accordance with the appropriate international data transfer mechanisms and standards.

Sensitive Personal Data

We do not generally seek to collect sensitive personal data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with local data privacy law requirements. If you choose to provide us with unsolicited sensitive personal data, you consent to our using the data, subject to applicable law as described in this privacy policy.

The term "sensitive personal data" refers to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories may include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

Protecting your personal data

Avanade protects your personal data in accordance with applicable laws and through its contractual commitments and privacy policies and procedures. Avanade has a global data privacy and data security policy which sets out the safeguards that apply across Avanade regardless of where we process your data. Avanade also has data privacy procedures describing how we should handle access requests or inquiries. Together, these ensure that appropriate data privacy safeguards are in place across our organization.

Your safe use of our Site

We take appropriate steps to maintain the security of personal data collected. Regarding your use of our websites, you should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting you to our systems without security measures, and your data may be accessed and used by people other than those for whom the data is intended.

From time to time, our site may contain links to and from the sites of our partner networks, advertisers and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies or sites. Please check these policies before you submit any personal data to these sites.

Processing of your Personal Data

As a global organization with distributed IT systems, personal data we collect may be routed, stored, or transferred internationally throughout Avanade's worldwide organization in accordance with our privacy policies and procedures, and in accordance with data privacy laws.

Retention of your Personal Data

We will retain your personal data only for as long as is necessary. Criteria we use to determine the retention periods include:

Retention of your data for as long as we have an ongoing or legitimate interest relationship with you.

Retention of your data for as long as needed for us to comply with our global legal and contractual obligations.

Your rights concerning your personal data

Please contact AvanadeDPO@avanade.com if you have any questions or concerns about how Avanade processes your personal data.

You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law to:

Request access to the personal data Avanade processes about you: this right entitles you to know whether Avanade holds personal data of you and, if so, obtain information on and a copy of those personal data.

Request rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.

Object to the processing of your personal data: this right entitles you to request that Avanade no longer processes your personal data.

Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.

Request the restriction of the processing of your personal data: this right entitles you to request that Avanade only processes your personal data in limited circumstances, including with your consent.

Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Avanade, or request Avanade to transmit such personal data to another data controller.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting SubjectAccessRequest@avanade.com.

Please note that this will not affect Avanade’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent. Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.

If, despite Avanade’s commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, Avanade encourages and welcomes you to come to Avanade first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Avanade with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

Questions and Concerns

You can find additional information about how we process your personal data in relation to websites, cookies, marketing and personnel below.

If you can’t find what you’re looking for in this statement, or have a concern about our use of your personal data, you may contact our Data Protection Officer (DPO) via e-mail at: AvanadeDPO@avanade.com.

AVANADE WEBSITES

This site is administered by Avanade, Inc. on behalf of itself and each Avanade local operating company.

Your privacy on Avanade websites

What information do we gather?

How do we use information that we collect from the site?

Your privacy on Avanade websites

The primary purpose of Avanade’s website is to be a dynamic resource and business tool to help you learn more about Avanade. We want you to feel secure when visiting our website and are committed to maintaining your privacy when doing so.

What information do we gather?

Avanade collects information through its websites in two ways: (1) directly (for example, when you provide information to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website's technology).

We may collect and process the following information:

Information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of information may provide further information as to why your data is needed and how it will be used. It is completely up to you whether you want to provide it.

If you contact us, we may keep a record of that correspondence.

We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

Any postings, comments or other content that you upload or post to an Avanade website.

Our website collects information about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.

Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies
section below for more information.

When this information relates to or identifies you, we will treat it as “personal data.”

How do we use information that we collect from the site?

We use personal data to provide you with information you request, process online job applications, and for other purposes which we describe or make obvious to you at the point where it is collected. For example:

To fulfill your requests for white papers, articles, newsletters or other content.

For surveys or research questionnaires.

To personalize your experience at our website.

To contact you for marketing purposes where you have agreed to this.

COOKIES AND SIMILAR TECHNOLOGIES

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience. Please see our Cookie Policy for more details.

AVANADE MARKETING

This section describes our use of personal data for marketing purposes, including:

Sources of marketing data

Targeted E-mail

Customer Relationship Management (CRM) Databases

Use of Avanade Websites

Combining and Analyzing Personal Data

Your Rights Regarding Marketing Communications

Sources of Marketing Data

The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients, other companies with which we have an existing business relationship, and job candidates seeking careers opportunities at Avanade. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.

Targeted E-mail

We send commercial and transactional e-mail (e.g. confirmation messages) to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and any links you may click. When you click a link in a marketing e-mail you receive from Avanade, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from Avanade may include additional data privacy information, as required by applicable laws.

Customer Relationship Management (CRM) Databases

Like all large companies, Avanade uses marketing automation and customer relationship management (CRM) database technology to manage and track our marketing efforts. Our customer databases include personal data belonging to individuals at our clients and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of known users of our website, and other business information included by Avanade professionals based on their personal interactions with you. If you wish to be excluded from our CRM databases, please use the Contact Us form.

Combining and Analyzing Personal Data.

As described above, we may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you. This information may include information collected across our different websites such as our careers and corporate sites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn and Xing). We combine this data to better assess your experience with Avanade and to perform the other activities described throughout our privacy policy.

Your Rights Regarding Marketing Communications

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our marketing automation and customer relationship management (CRM) databases at any time by using our Contact Us form. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

AVANADE PERSONNEL

If you are an employee (or an individual contractor), candidate or alumni, Avanade will process your personal data in accordance with this privacy statement as well as with the information available on our alumni website and recruitment site when applying for a job.

If you use any specific Avanade tools or websites aimed at employees, candidates and alumni, we collect personal data that you submit to such tool or website. In addition, we may collect personal data from third parties such as previous employers and educational institutions.

We may also use Cookies and other tracking technology and the same technologies we use for Marketing (including Customer Relationship Management (CRM) Databases, Targeted E-mail & Combining and Analyzing Personal Data) to provide individuals with a personalized online experience, to send relevant information, and to analyze the effectiveness of our efforts and resources.

AVANADE OFFICES

In addition to the information set out above, this section describes how we use personal data when you visit Accenture offices.

Please click here to receive further details on how we process your personal data when visiting our offices (this sub-page also relates to the potential processing of your personal data through CCTV and access management systems in case such CCTV and access management systems are active.)

If you have any questions on data privacy or you want to let us know about website/marketing permissions, please contact us at AvanadeDPO@avanade.com.